STATE OF RHODE ISLAND FAMILY COURT
MARGARITA E. PALANGE,
vs. C. A. NO. W12-0361
STEVEN J. PALANGE,
MOTION TO ADJUDGE IN CONTEMPT
NOW comes the Plaintiff, MARGARITA E. PALANGE, and states that this Honorable Court did issue an Order dated June 13, 2018 which restrained and enjoined the Defendant from bothering, harassing or interfering with the Plaintiff at any time or place; that since that time, Defendant has embarked on concerted effort through internet postings to damage the reputation of the Plaintiff and otherwise harass the Plaintiff by, amongst other things, disparaging Plaitniff’s parenting skills and relationship with her daughter; Plaintiff has recently specifically named Plaintiff and the child in his disparaging comments; said conduct is an intentional violation of the Orders of this Court.
WHEREFORE, PLAINTIFF PRAYS:
1) That the Defendant be adjudged in willful contempt for his aforesaid conduct;
2) That this Honorable Court restrain and enjoin the Defendant from mentioning the Plaintiff in any fashion, and from publishing the minor child’ name, on the internet or in any other forum;
3) That this Honorable Court award Plaintiff sole custody of the minor child insofar as Defendant’s conduct is indicative of his inability to cooperatively parent with the Plaintiff as required by Duke v. Duke, 510 A2d 430 (RI 1986) and Horton v Horton, 891 A2d 885 (RI 2006).
4) That the Defendant be ordered to pay for the reasonable costs incurred by the Plaintiff in prosecuting this motion, including a reasonable counsel fee; and
5) That the Plaintiff be awarded such other and further relief as this honorable court may deem just.
By her attorney
/S/ Richard E Updegrove, Jr., Esq.
UPDEGROVE LAW, LTD.
Richard E. Updegrove, Jr., Esq.
314 Oliphant Lane
Middletown, Rhode Island 02842
(401) 847 5684 Bar No. 2245
THIS MATTER IS ALREADY ON THE CALENDAR FOR HEARING BEFORE THE WASHINGTON COUNTY FAMILY COURT ON THE 24TH DAY OF SEPTEMBER, 2018 AT 9:00 A.M.
CERTIFICATE OF SERVICE
I hereby certify that, on the 7th day of August, 2018:
□ I filed and served this document through the electronic filing system on the following parties: _______________________________________.
The document electronically filed and served is available for viewing and/or downloading from the Rhode Island Judiciary’s Electronic Filing System.
□ I served this document through the electronic filing system on the following parties:
The document electronically served is available for viewing and/or downloading from the Rhode Island Judiciary’s Electronic Filing System.
□X I mailed/faxed/emailed or □ hand-delivered this document to the attorney for the opposing party and/or the opposing party if self-represented, whose name is
TANYA GRAVEL, ESQ., at her normal email address .
/S/ RICHARD E. UPDEGROVE, JR.
Good afternoon Steven,
Attached, please find the notice of deposition from Attorney Updegrove as well as the subpoenas he issued for two police officers to show up at the next hearing date. Since you are not providing your financial statement to him and the court, he is subpoenaing the records from the Keeper of the Records of your company to find out how much money you make so that child support can be calculated.
Thank you. And if you keep working for me….I’ll keep Paying you.
So far Everything has worked out just fine. Exactly as I Wanted! So far….
And I do mean exactly…but nowhere near as good as I ever Dreamed!!!
I Make my life happen…even within the corruption that is Family Court.
I spoke to Katerkna last night via Skyoe. They are abusing the HELL out of her! Emotionally and physically. She begged me to save her!
But thanks to the RI Family Court her mom’s boyfriend gets to keep Abusing her!
She begged me to save her!
Add me on Snapchat! Username: stevenp1960 https://www.snapchat.com/add/stevenp1960